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REACH - A few of the hundreds components in my product no longer meet requirement

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ProblemChild

#1
How could it impact the business if all of sudden few of the components used in the product ( electronics assembly) are found to have the new restricted substances per the ever-increasing chemical list under REACH?

Are we obligated to replace those affected parts, have our customers to re-qualify the products ( assuming some of those parts are critical), before we can import our product into EU?

Anyone here has been asked by their tier 1 customer to replace the part if it does not meet the updated list's requirement?
 
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mattador78

Quite Involved in Discussions
#2
Speaking of my own experience of REACH it depends upon the usage of your parts most Aerospace Automotive and Defence parts are exempt anyway. Also many products are still available after their sunset date due to appeals from major companies, our usage of chromium trioxide is covered by a letter of assurance that the product was purchased through one of the 7 major companies who appealed against the withdrawal of the chemistry.
google jonesreachday ctac as I cant post links on here yet
It is a bit of a minefield As you can see this isn't information REACH make easily available on their website. Hope it gives you an idea
 

QuinnM

Involved In Discussions
#3
Hi ProblemChild,

Assuming you are a business outside the EU…

If you are referring to the SVHC, Substances of Very High Concern, then the requirement is to notify the recipient of the article. You do not have to remove these from your product(s).

If you are referring to the Substances restricted under REACH, then you are correct the substances have limited use, or are banned.

As mattador78 noted maybe you are exempt.

Take care,
Quinn
 
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